4.0 Objection to the traffic modelling and analysis of alternatives to WestConnex

posted by WestConnex Action Group | 2318.80sc
February 11, 2016

WAG strongly objects to the traffic modelling and analysis of alternatives to building the WestConnex New M5 included in the EIS.

Nearly all other claims in the EIS depend for their validity of the traffic analysis. However, there are major issues with the Traffic and Transport Assessment.

The Traffic and Transport Assessment does not stand up to scrutiny for a number of reasons:

● The EIS does not provide enough information about the methodology, input data or assumptions used in the assessment for the forecasts to be independently verified.

● It does not include a sensitivity analysis. The effects of varying key assumptions (e.g. drivers’ willingness to pay the New M5 toll) have not been disclosed. How will traffic volumes be affected if (when) the willingness to pay for the toll is different to the point estimate used?

● It has failed to model the travel time and accessibility impacts for non-motorised modes (walking and cycling).

● The issue of induced demand is acknowledged but has not been fully addressed and is likely to have been underestimated.

● Impacts of disruptive technology (e.g. automated vehicles) on future driving demand have not been not considered

● Intergenerational changes in vehicle ownership, driver licensing and transport preferences have not been considered.

● Changes in aggregate transport measures have not been provided for the various scenarios, such as:

○ Overall increase in VKT

○ Change in average trip distance

Given the seriously flawed Traffic and Transport Assessment, there can be no confidence in the accuracy of the other impact analyses in the EIS that are dependent on the traffic forecasts, in particular:

· Air quality

· Noise and vibration

· Human health

· Greenhouse gas emissions.

As outlined in Section 1.0 of this submission, the stated objectives for the project were contrived to fit the project after it had already been announced. In a democratic strategic planning process, objectives are set first based on the needs and desires of the community, and then alternative projects/policies are appraised against their ability to meet those objectives.

The EIS has not modelled alternative policy scenarios that could meet the transport and accessibility needs of NSW's growing population, such as greater investment in public transport, road pricing reform, and land use planning that places more homes closer to employment and services.

It is no secret that the real purpose of the WestConnex scheme is to increase the road freight accessibility of Port Botany and Sydney Airport, and that private passenger vehicles have been included as a means of paying for it through tolls. However, there are various policy alternatives for dealing with the growing freight task that do not appear to have been considered, such as:

· Diverting container operations to other ports outside the city centre. Very few cities concentrate container operations in the city centre where road access is costly and has significant impacts on highly populated areas.

The New M5 and the WestConnex of which it is part will be used by less than 1% of the NSW population each day. The costs will be borne by the whole population. It can hardly be argued that it is providing for the "greater good".

The role of motorways in a multimodal urban transport network is to allow traffic to circulate around the edge of a city connecting low density suburbs, where the traffic does not directly impact highly populated areas. For radial transport into and out of employment and activity centres, mass transit is faster and more efficient, requires less space, and has fewer impacts on highly populated inner-urban areas.

The EIS does not consider the cumulative costs of adding more urban motorways to those previously built through the heart of Sydney since the 1950s. Although the economic, social and environmental costs of each individual motorway (as reported in an EIS) may be considered by some stakeholders to be acceptable, the cumulative costs are considerable:

· Following decades of road expansion and consequential sprawl, Sydney now spends about 13% of its GDP on transport, while the average European or Asian city spends only between 5% and 8%.1

The EIS also fails to consider the cumulative negative impact of the WestConnex project as a whole, even though it repeatedly cites the supposed benefits of building the entire motorway as justification for building the New M5. At a minimum, it would be expected these would worsen the kinds of factors cited in the previous point, but this is not addressed in any meaningful way in the EIS.

Induced demand for tollways can happen at the same time as overall demand for driving drops due to other changes. It is crucial that all parts of Sydney have adequate public transport. Current plans for private light rail may help but certainly do not address the appalling under investment in public transport in Western Sydney.

The proposal is based on the idea that demand for road capacity will increase over time, without taking into consideration the changes in transport choices that different generations will make for a range of reasons, including environmental considerations, economics and the ease of public transport compared to congested roads.

Not investing in better public transport not only impacts on the communities around the St Peters interchange, but also leaves commuters with no option but to rely on their cars, in turn guaranteeing that congestion will increase over time.

4.1 SEARS not met

The EIS also fails to meet a number of the project’s SEARs as detailed in the following table.

SEAR

Requirement met?

Reasons SEAR not met

An analysis of feasible alternatives to the carrying out of the proposal and proposal justification, including:- an analysis of alternatives/options considered, having regard to the proposal objectives (including an assessment of the environmental costs and benefits of the proposal relative to alternatives and the consequences of not carrying out the proposal), and whether or not the proposal is in the public interest,- justification for the preferred proposal taking into consideration the objects of the Environmental Planning and Assessment Act 1979,- details of the alternative ventilation options considered during the tunnel design to meet the air quality criteria for the proposal,- details of the short-listed route and tunnel options from the tender process and the criteria that was considered in the selection of the preferred route and tunnel design, and- staging of the proposal and the broader WestConnex scheme, and in particular access to Sydney Airport and Port Botany and improved freight efficiencies.

No

The EIS does not include cost-benefit analysis, modelling, or any other objective analysis of feasible alternatives. Only cursory descriptions are provided. No alternative staging strategies are described or objectively assessed.

Details of the proposal’s relationship to and consistency with the broader WestConnex, and an assessment of the cumulative impacts taking into consideration the WestConnex program of works.

No

Cumulative construction impacts for the New M5 and other WestConnex projects have not been modelled/reported. Only a cursory description of cumulative impacts is provided. The assessment of operational cumulative impacts does not include past/existing developments, in particular existing arterial roads and motorways. Although the economic, social and environmental costs of the proposed New M5 on its own may be considered by some stakeholders to be acceptable, the cumulative costs of this and previous/existing/planned motorway developments are considerable:1. Following decades of road expansion and consequential sprawl, Sydney now spends about 13% of its GDP on transport, while the average European or Asian city spends only between 5% and 8%.12. Serious human health impacts due to petrochemical vehicle emissions/smog, including:a. Lung cancer,b. Asthma,c. Heart disease,d. Impaired lung development and nervous system development in children living near motorways/exhaust stacks.3. Waterways contaminated with road runoff (heavy metals and carcinogens in brake and clutch dust, exhaust particulates etc.).4. High traffic crash costs (deaths/traumatic injuries and material damage).5. Urban sprawl and increasing commuting distances.6. Social isolation for non-drivers living in car-dependent suburbs.7. Noise pollution from traffic and its impacts on sleep.8. Impacts on visual amenity (pollution stacks, concrete interchanges, concrete flyovers).9. Extreme summer temperatures (urban heat island effect).10. Community destruction and severance.11. Destruction of heritage.12. Irreversible Biodiversity loss.13. Less incidental physical activity from walking and cycling (including to/from public transport), resulting in higher rates of obesity, diabetes, cancer and heart disease.14. Increased chauffeuring burdens for parents and carers.15. Less independence for children.16. High per-capita greenhouse gas emissions.

Details of how the proposal meets the objectives of the overall WestConnex program.

The proposal does not meet the program objectives (see section 3 below).

An assessment and modelling of operational traffic and transport impacts on the local and regional road network (in consultation with affected councils), and the Sydney motorway network, including the consideration of planning proposals, major urban renewal and development, the potential cumulative impacts of Stage 3 – M4 South (Haberfield to St Peters), and the impacts of potential shifts of traffic movements to alternative routes outside the proposal area (including as a result of tolls).

No

The assessment of operational traffic and transport impacts is limited to a small study area around the project site. However, there will be significant traffic and transport impacts outside the study area, and indeed throughout the whole Sydney metropolitan area. The assessment of operational traffic and transport impacts ignores delays at new on-ramps and off-ramps. The EIS does not include any objective assessment or modelling of impacts on pedestrians and bicycles using the local and regional road network. Pedestrian and bicycle movements have not been included in the strategic model (WRTM) nor the intersection models (LinSig). There is no forecast of the impacts on walking and bicycling travel times and accessibility. As such the EIS does not provide a complete “assessment and modelling of operational traffic and transport impacts”, it provides only an objective assessment of motor vehicle and public transport impacts within a small part of the area affected.

Induced traffic and operational implications for public transport (particularly with respect to strategic bus corridors and bus routes) and future public transport opportunities.

No

Induced demand has not been adequately accounted for because:1) The model ignores the induced demand caused by long-term transport decisions of individuals and firms, including:a)Residential location choice – the project will encourage more people to move further from work (sprawl), thereby increasing average travel distances/demand.b)Work location choice – the project will encourage more people to work further from home, thereby increasing average travel distances/demand.c)Car ownership choice – the project will encourage more car ownership and use.d)Firm location choice – the project will encourage firms to locate in locations further away from their labour supply/customers/suppliers than they otherwise would, thereby increasing travel distances/demand.2) To WAG’s knowledge, there has been no long-term evaluation/verification of the methodology used to forecast induced demand (New Zealand Transport Agency Economic Evaluation Manual (EEM)). Induced demand by its nature materialises over several years, as people gradually move home/work location etc. Without a long-term evaluation/verification of the methodology, there can be no confidence in the induced demand forecast produced.

Impacts on cyclists and pedestrian access and safety and consideration of opportunities to integrate cycleway and pedestrian elements with surrounding networks.

No

The EIS does not include any objective assessment or modelling of impacts on pedestrians and bicycles using the local and regional road network. Pedestrian and bicycle movements have not been included in the strategic transport model (WRTM) nor the intersection models (LinSig). There is no forecast of the impacts on walking and bicycling travel times and accessibility.

An assessment of construction and operational activities that have the potential to impact on in-tunnel, local and regional air quality. The air quality impact assessment must provide an assessment of the risk associated with potential discharges of fugitive and point source emissions on sensitive receivers.

No

An accurate assessment of air quality impacts is dependent on an accurate assessment of traffic and transport impacts. Because the traffic and transport impacts have not been correctly modelled, the air quality impact assessment is worthless.

An assessment of human health impacts.

No

An accurate assessment of human health is dependent on an accurate assessment of traffic and transport impacts. Because the traffic and transport impacts have not been correctly modelled, the human health impact assessment is worthless.

An assessment of the noise impacts of the proposal during operation, consistent with the Road Noise Policy (EPA, 2011) and NSW Industrial Noise Policy (EPA, 2000).

No

An accurate assessment of noise impacts is dependent on an accurate assessment of traffic and transport impacts. Because the traffic and transport impacts have not been correctly modelled, the noise impact assessment is worthless.

4.2 Objections to the Traffic and Transport Assessment - Appendix G

General comments

The Traffic and Transport Assessment does not stand up to scrutiny. There is not enough information about the methodology, input data or assumptions for the forecasts to be independently verified.

The study area is too small to capture adequately the traffic and transport impacts of the project. The project will affect home location choice, work location choice, trip generation, destination choice, mode choice and route choice across the whole metropolitan area.

For example, people travelling between Penrith and the Airport will have a number of options (train; drive via M7/M2; drive via M4; drive via M7/M5; drive via un-tolled roads).

The resulting changes in travel behaviour will have implications for local and regional traffic and transport throughout the Sydney metropolitan area. For example, more Penrith residents may be encouraged to drive to the city rather than use the train, which will (a) increase traffic volumes and associated impacts on local/regional roads in/around Penrith and (b) reduce rail patronage, which could in turn lead to reduced service frequencies affecting remaining rail users.

The Traffic and Transport Assessment does not assess or even acknowledge these traffic and transport impacts beyond the study area.

There is no sensitivity analysis in the Traffic and Transport Assessment. The effects of varying key assumptions (e.g., willingness to pay the tolls) have not been described.

The travel time calculations do not appear to include delays at on-ramps and off-ramps. Although it is not even mentioned in the Traffic and Transport Assessment, the Business Case states that ramp metering will be used. This will cause delays for travellers entering/exiting the M5; these delays have not been included in the Traffic and Transport Assessment.

Travel time and accessibility impacts for non-motorised modes (walk and bicycle) have not been modelled or objectively assessed.

Impacts of disruptive technologies on future driving demand have not been not considered (e.g., automated vehicles).

Inter-generational changes in vehicle ownership, driver licensing and transport preferences have not been considered.

Changes in aggregate measures have not been provided for the whole study area, nor for the wider metropolitan area, e.g.,:

1. Overall increase in VKT.

2. Change in average trip distance.

3. Change in average trip duration.

4. Change in total travel time.

Section 3 Strategic context

The stated justification for the project is based on the discredited 'predict and provide' approach to transport planning, whereby it is assumed that transport demand will continue to grow, and that capacity must be increased to accommodate it. In practice, transport demand in cities is limited by capacity: as capacity increases, so does demand (induced demand). It is geometrically impossible to provide enough roadway capacity to accommodate all the latent demand for driving (i.e., where everyone can live and work where they want, and make all the driving trips they want, when they want, to wherever they want in free-flow traffic) in a city of Sydney's population.

Furthermore, the most efficient way to accommodate the transport and accessibility needs of a growing population is through mass transit and better land use-transport integration. Urban motorways are a very inefficient way of moving people around. A single traffic lane can transport a maximum of only 2000 people per hour (in ideal conditions); a single railway line can transport 20,000 people per hour.

The statement "It is acknowledged that any investment in motorway infrastructure has to be aligned with supporting public and active transport initiatives to achieve an increase in capacity, while aiming to reduce the reliance and demand of private vehicles on the future road network" is contradictory: increasing motorway capacity will only serve to increase private vehicle demand.

Assessment methodology

There is not enough information about the modelling methodology for it to be replicated and the outputs independently verified.

The transport model (WRTM) has not been made available for independent verification.

The model input data and assumptions have not been made available for independent verification. E.g. what toll prices have been assumed?

The model coverage area is too small to capture all the transport impacts of the project. The project will affect transport demand and behaviour across the whole metropolitan area.

More detail on the Value of Travel Time Saving (VTTS)/Willingness to Pay (WTP) model is needed. For example:

The form and parameters of the model have not been given.

If it was based on stated preference surveys, then how has the issue of hypothetical bias been addressed?

Has the model been validated? Previous toll choice models in Australia have overestimated WTP for toll roads.

Does it include the negative utility of the tunnel environment (monotony, no natural light, poor air quality)?

Does the WTP estimate take into account tolls that motorists currently pay (toll saturation)? E.g., a road user may be willing to pay an additional $10/day if he/she currently pays nothing, but not willing to pay an additional $10 if he/she is already spending $15 on tolls.

The weekend period has not been modelled, despite current weekend traffic volumes being higher than weekday traffic volumes on many corridors.

The EIS provides insufficient information about the travel zone structure in the WRTM, including:

· What are the travel zones based on? How big are they?

· How are intra-zonal trips modelled?

· How are trips to/from external zones modelled?

Induced demand has not been fully addressed in this EIS. The model ignores the impact of the project on the long-term transport decisions of individuals and firms, including:

· Residential location choice: the project will encourage more people to move further from work (sprawl), thereby increasing average travel distances and demand for driving.

· Work location choice: the project will encourage more people to work further from home, thereby increasing average travel distances/demand.

· Firm location choice: the project will encourage firms to locate in locations further away from their labour supply/customers/suppliers than they otherwise would, thereby increasing travel distances/demand.

There appears to have been no long-term evaluation/verification of the methodology used to forecast induced demand (New Zealand Transport Agency Economic Evaluation Manual (EEM)). Induced demand by its nature materialises over several years, as people gradually move home/work location etc. Without a long-term evaluation/verification of the methodology, there can be no confidence in the induced demand forecast produced.

Non-motorised trips have not been included in the WRTM or LinSig modelling.

Impacts on accessibility have not been modelled.

Most transport is not an end in itself; it is a means to access work, education, services etc. How does the project affect population accessibility? This EIS does not consider this.

Equity and equality impacts not described. For example:

· How many people are better off with the project?

· How many people are worse off with the project?

· Do benefits/impacts accrue to any population groups more than others, e.g., people with a disability or on low incomes?

The Downs-Thomson Paradox has not considered. The project will attract passengers away from public transport to road. As such, public transport patronage will be lower than it would be without the project. This could result in public transport service levels being cut, which will encourage further mode shift from public transport to road.

Given the numerous assumptions and approximations in the model, there needs to be some sensitivity analysis, e.g. How will traffic volumes be affected if (when) the WTP for the toll turns out to be lower than the point estimate used? Yet no such sensitivity analysis has been performed.

Assessment of construction impacts

Impacts on travel times for all modes (driving, public transport, walk and bicycle) have not been assessed/reported. The construction activities will delay travellers in a number of ways, e.g.:

Cumulative construction impacts for the New M5 and other concurrent projects have not been modelled/reported. Only a cursory description of cumulative impacts is provided.

Future year traffic volumes and patterns

Tables 79, 80, 81 do not include the base year (2012) values, so the future 'with project' scenarios cannot be compared with current conditions.

Figures 67, 68, 69, 70, 71, 72 do not include the base year (2012) values, so the future 'with project' scenarios cannot be compared with current conditions.

An assessment of the impacts on walking and bicycle demand and travel times has not been provided.

Future conditions with the project

Delays at on-ramps and off-ramps have been omitted from the travel time forecasts, so actual travel times will be significantly higher than those forecast.

The reported travel times savings have been selectively chosen to show only those routes where travel times are forecast to decline (i.e., the M5 itself). The impacts on travel times for adjacent routes have not reported, in particular Stony Creek Road, 1)Canterbury Road Forest Road and Queens Road. Travel times on these routes will increase significantly due to the large increase in traffic diverting to avoid the M5 tolls.

Network performance measures (VKT, total travel time, average speed etc.) for the whole study area (nor for the whole metropolitan area) have not been modelled or reported. Only performance measures for the immediate area around the St. Peters Interchange have been reported.

Tables 99 and 100 of Appendix G of the EIS compare 'without project' to '2021 with project' and '2031 full WCX'. Figures for '2031 with project' are missing. WAG is aware that when Ben Aveling of Alexandria Residents Action Group (ARAG) enquired as to the missing information, he was told via an email from Louise Bonny of the SMC dated 13 January 2016 that:

“As described in section 10.3.2.1 of Appendix G, for the “2031 ‘with project’ scenario” there is a significant increase in local trip generation and in the traffic demand to and from the WestConnex portal at St Peters. This increase would need to be accommodated by the surrounding road network without any increase in road space (i.e. without the future proposed WestConnex M4-M5 Link, Sydney Gateway and Southern extension projects).

“As noted in Section 10.3.2.1 (page 252), Paramics modelling suggests that only about 80 per cent of the traffic demand in the 2031 ‘with project’ scenario could be accommodated by the existing road network. Modelling a scenario that can only accommodate 80 per cent of the demand results in outputs that are confusing as the model does not function properly and presents results that can be misleading.

“As noted in Section 10.3.2.1, in the absence of the development of the full WestConnex program of works, Sydney Gateway and the Southern extension, additional network upgrades would be required to accommodate the 2031 ‘with project’ traffic demand in the St Peters interchange area....

“Although there is a significant increase in traffic demand in the 2031 ‘full WestConnex and Southern extension’ scenario, the construction of the additional road network components proposed as part of the WestConnex M4-M5 Link, Sydney Gateway and Southern extension projects provide the additional road space and increases the ability to distribute and accommodate the predicted increase in traffic.”

Ms Bonny also stated that “Responses to these questions will also be addressed in the New M5 Submissions Report.”

If the proponent cannot even model the impact of the project without other unplanned and largely unfunded toll road projects, it should not be seeking planning approval for the New M5 as a standalone project. This EIS and proposal should be rejected on this basis alone.

Future conditions without the project

Impacts on walking and bicycle demand and travel times have not been modelled.

Does the LinSig intersection modelling take into account the impact that changes in intersection LOS will have on travel demand?

Failure to properly model impacts on King St, Newtown and surrounding area

WAG has been part of a massive campaign around King Street. Businesses are extremely worried. Although they have been represented by the Newtown Business Precinct there has been no attempt to consult with them directly. This is a major gap in the community feedback report. Indeed the CEO of SMC and the SMC’s New M5 Project Director paid one visit to Enmore Theatre for a meeting at which it was clear that there was huge opposition to WestConnex and have not been seen again. Other submissions will have addressed the value of King Street as a precinct. We endorse these. We also stress that the King Street precinct extends down both Erskineville Road and Enmore Road that both be massively impacted by traffic flowing into Euston Road and Edgeware Rd. The impact of this is not even mentioned in the EIS.

Claims that there would be no significant changes to traffic on King St (Page 13-48) do not hold up to scrutiny when there are predictions that traffic on Campbell St, St Peters, alone will increase from around 13,000 traffic movements per day currently to around 59,000 movements per day in 2031. There is nowhere else for this traffic to go but into surrounding local roads, including King St, which will be placed under pressure to be expanded or have clearways introduced, killing the existing amenity.

There have been some suggestions that various intersections will be blocked to stop the flow but these solutions will have massive effects on residential areas nearby. The fundamental flaw in the project cannot be fixed with a small number of traffic tweeks.

Figure 9-1 shows that the traffic study area has been limited to local roads in close proximity to the proposed alignment and does not take into consideration roads that will also be directly impacted by the project. For example, only the lower part of King St, Newtown has been included in the study area, despite the whole road being used currently as a main arterial route. There is no information in the EIS at all about what will occur North of Alice Street.

Edgeware Road, Marrickville has not been included when traffic will be funneled directly from the project onto this road via Campbell St.

The EIS clearly states that “...no regular bus services operate along the M4 East Motorway or the M5 South West Motorway…” and that there “is a commitment to deliver bus priority along the M5 Motorway Corridor…” but gives no further detail on why this is not being pursued as a solution to existing commuter traffic congestion. Why is this not being given a priority as it would be a cheaper, quicker and better environmental outcome than pursuing this proposal which is expensive, will not significantly improve traffic congestion, will have irreversible and detrimental environmental impacts and to which there is strong community opposition?

The EIS (Table 9-17) does not include a survey of traffic volumes on Unwins Bridge Road, despite it being a major road in the vicinity of the proposed St Peters interchange and one that already experiences high volumes of AM and PM peak traffic. The EIS states that performance at some intersections would improve without the project due to other factors and the predictions made on page 13-45 show that some local roads would experience increases in congestion as a result of the project – this is evidence that this is an outdated transport solution as it does not actually fix the problem it purports to, which is reducing congestion.

There is information presented in the EIS showing that the purported benefits of the New M5 would not be realized without other projects being completed. As there is no certainty that these other projects would be funded, approved or built, there needs to be a proper analysis of what the consequences would be if these projects do not proceed.

From the limited amount of traffic modelling that has been done, WAG’s analysis shows that In the Peak AM, 11 major intersections in St Peters and Alexandria would be the same or worse with the Westconnex after the New M5 is built in 2021, and in 2031.In the PM peak, 7 intersections would be the same or worse off. The NSW government is deliberately planning to make traffic congestion, which is already a costly risk to health and liveability, worse. Drivers would be paying expensive tolls only to end up in a traffic jam losing where limited savings are lost.

AM Peak Intersections that would be the same or worse off in 2031 include

Princes Highway/Sydney Park Rd

Princes Highway Campbell Street

Princes Highway Canal Rd

Sydney Park Rd and Mitchell Rd

Sydney Park Rd Railway Rd

Sydney Park Rd Euston Rd Huntley St

Unwins Bridge Rd Campbell St

Campbell Street Euston Rd

Campbell Rd Burke St

Gardeners Rd Burke St

Gardeners Rd O Riordan St

PM Peak

Princes Highway/Campbell St

Princes Highway Railway Rd

Sydney Park Rd Euston Rd

Unwins Bridge Rd Campbell Street

Campbell Rd Euston Rd

Gardeners Rd Burke Rd

Gardeners Rd Riordan Rd

This analysis is drawn from Tables 99 and 100 in the Traffic Analysis. If our analysis is wrong tell us exactly why and which ones are wrong.

What sort of transport planning merely aims to make one spot a little better while another is a little worse. If the government approves this project it will be consigning a whole region of population growth to endless traffic congestions.

‘Without project’ scenarios do not allow for any other solution that might have been found to lesson traffic through providing better public transport, traffic management and through changing work patterns.

Even some of those intersections that would improve would not do so until after parts of the growing Westconnex system that are currently not ‘plans’ at all - just political concepts. Most community members find it shocking that a government would proceed to spend billions of dollars on this project.

When WAG has asked at EIS sessions for an explanation of why the traffic modelling was not done beyond two intersections, we were told that this was a decision collaboratively made by AECOM and RMS. This decision could only have been made to try to hide the impact on local roads which of course will become a costly public problem that will be isolated from the costs of Westconnex when it should rightfully be included in the total estimates of cost for Westconnex.

WAG objects to the traffic modelling being so limited in scope and not being independently verified when such a vast amount of tax-payers money and significant environmental and social impact is at stake. Given the flaws in traffic modelling for previous largescale motorway projects in Sydney and other Australian cities, it is vital that the traffic modelling be independently verified and submitted for public consultation prior to project determination.

4.4 Poor analysis of alternatives

There is a big problem with both the Proponent and the RMS, the client for this project having a primary purpose of building new roads, rather than being focused on wider transport options, as they will by nature propose that a new motorway is the preferred solution despite overwhelming evidence showing that this is project should not be built. This is a fundamental problem with the whole EIS.

The EIS discussion of other options to reducing congestion and improving the M5 all focus on road solutions and repeating earlier road schemes and strategies, rather than providing a comprehensive analsyis of different transport solutions. The EIS does not meet the requirement to provide a true analysis of alternatives, such as improved public transport and better traffic management.

The summary in Section 4.1.1 in relation to the strategic concept for the M5 East Duplication shows that the community has previously raised concerns, including about air quality, biodiversity and traffic impacts, with having a motorway extension in this area. These concerns are not adequately addressed by the current proposal, as it is in direct conflict with the community’s wishes, making a mockery of the consultation process and showing how little consideration the Baird Government and Westconnex has given to feedback from the community.

Section 4.2.2 outlines reasons for why a project focused only on improving the existing M5 motorway is not preferred, including “significant constructability, social and environmental impacts to existing residential and commercial development along these roads” and that improvements to one section “would increase the demand on adjacent sections of the road network such as the airport tunnel which is already operating at or near capacity…and has limited capacity to cater for additional traffic.” Given these same impacts would arise from constructing the proposal, it is nonsense to use these as reasons for not improving the existing M5 yet proposing to impose the same impacts when building the new M5, which would be at a much larger scale of impact.

The discussion on public transport alternatives does not address any of the specific details of the movement of commuters and freight along the proposed alignment, apart from some general discussion about the East Hills rail line.

There are currently no commuter busways up the existing M5. This provides a chance for taking at least some of the commuter cars off the existing M5 by provision of busways which in turn would provide more capacity on this road for the short-haul freight journeys that the proposal is supposedly trying to address. The summary that “no feasible strategic transport alternatives such as heavy rail or light rail options or bus corridor enhancements would meet the diverse range of customer needs…” is not supported by any detail.

Analysis in the context of planning should surely include some presentation and comparison of evidence including quantitative information. The alternatives section reads like an afterthought rather than a genuine consideration of alternatives.

Section 4.2.3 outlines predicted population growth and implies that while the majority of this growth will reside in western Sydney where there is more affordable housing, most jobs will still be located in the east – surely this supports the argument for investment in more public transport now rather than investing in a road that will only become more congested with future population growth? As the CEO of the City of Sydney told a Sydney University forum last year, there is something fundamentally wrong with continuing to skew Sydney’s transit systems to the edge. This project simply embeds the traditional short sighted thinking.

This section also states that “..to have a major impact on road traffic, demand management measures would require considerable changes to social attitudes, travel behavior and government policy.” This appears to be a justification for not more actively pursuing demand management measures, No detailed reasons are given for why demand management is not going to be more actively pursued. Given this proposal is being developed and championed by the Government, it is puzzling that government policy is used as an excuse not to do something in this context. Government policy can have a significant impact on social behaviours and attitudes when used proactively and constructively. It is worrying that the push for WestConnex is not occurring in the context of other more enlightened government policy development.

Table 4-2 assesses each of the project objectives against strategic alternatives. The first objective is focussed on improving motorway access, showing that at the heart of the proposal there is an agenda to only build a new motorway and to shape all justification around this, rather than considering and analysing true alternatives. Given this, it is unsurprising that only the new M5 options ticks all of the boxes of this assessment, but it does show the cynical way in which the Proponent and Government is trying to push this project onto a community that clearly does not agree with the need for it, or with the approach being taken by the Government.

Selection of St Peters for the northern interchange location has been made on the basis that the impacts to freight and industry stakeholders would be too great if other options were explored. Given that displacement of freight and industry does not have as great a social, visual or noise and vibration impact as the residential displacement that is being proposed, this does not make it an adequate justification.

Statements that the St Peters interchange is designed to “draw through traffic off local roads” and “distribute traffic using the established urban arterial road network where possible…” are ridiculous given that the increase in traffic that is being predicted for this project will have nowhere to go but the local road network, which is not proposed to be upgraded beyond the proximate junctions with the interchange.

We object to the inadequate analysis of alternatives that have been provided as part of the EIS as it does not meet the requirements of the SEARS, particularly the clauses relating to whether or not the proposal is in the public interest andjustification for the project taking into consideration the objects of the Environmental Planning and Assessment Act 1979.

4.6 Objections to operational impacts

It deals with the impact of the operation of the New M5 EIS as assessed in the 150 page Chapter 9 of the EIS and associated 298 page Appendix G. Part 1 provides an assessment of the information in the EIS relating to the construction of the project.

In reading and analysing the Traffic and Transport section of the M5 EIS, the following points and concerns are noted.

The “Full WestConnex program of works and Southern extension (2031)” includes all WestConnex projects as completed, although does not include the M4-M5 Link additional harbour crossing or CBD north access at Rozelle, as the ANZAC and Harbour Bridges are already at or close to full capacity as acknowledged by the report (Appendix G, p. 33). Those aspects that will benefit the case for the M5 project, particularly regarding traffic modelling, are included (such as the “Full WestConnex project”), but where the case might struggle they are excluded

NSW Freight and Ports Strategy (Transport for NSW)—this strategy is used to justify that provision of an alternative route and saved travel time would lead to network sustainability outcomes through “long-term savings in greenhouse gas emissions” (Appendix G, p. 26), however it would be necessary to show further evidence regarding how extending a road will reduce greenhouse gas emissions, given the complicated effects of induced traffic demand, among other phenomena. Also, is this the more “sustainable” option compared to improving the rail freight network over the same period (shifting freight to rail is after all a priority for the NSW Government)?

The fact that the WestConnex Road Traffic Model has two components, and one of them is a Toll Choice Assignment Model specifically to try to predict toll choice behaviour (see Appendix G, p. 31) indicates the impact of tolls on driver behaviour, and that those charged with modelling the project are highly concerned with the effects of the tolls on matters such as “rat running” and on the economic viability of the project. It must be remembered that figures produced from this aspect of the modelling are not certainties, and far higher numbers of people might choose to avoid tolls and “rat run” for any number of reasons

Land use projections, such as known major urban renewal and developments, as well as induced demand are claimed to be considered in modelling (see Appendix G, p. 32)—It is extremely difficult to determine the exact effect of new urban development on travel behaviour—for instance the creation of a local precinct might greatly reduce the impetus for residents to use or even own a car—and predicting induced demand is a complex and imprecise practise in itself (not to mention that the many negative impacts of induced demand are glossed over and not mentioned at all in this section of the report)

The “modelled years” have been chosen specifically as those that represent the best traffic modelling case for the M5 project:

- 2021: Despite the project projected for completion in 2019, 2021 is used as the forecast year “to allow for full ramp-up of traffic demand as travellers respond to the provision of the project” (Appendix G, p. 32)

- 2031: Used as the “10 years after opening [case] as required in the Roads and Maritime assessment guidelines” (Appendix G, p. 32), despite, as mentioned above, project completion projected for 2019. This modelling, then, does not meet RMS assessment guidelines

The paramics modelling produces four hour peak periods, but this data is only available from the traffic forecasts in one hours sections, so “The forecast one-hour value was spread across the four-hour period to reflect a typical peak shoulder profile” (Appendix G, p. 38). This simply reinforces the point that with all traffic modelling, but especially at this scale, there is a high amount of approximation, appropriation and estimation of data—which is not appropriately acknowledged throughout subsequent parts of this traffic section, or indeed throughout the entire EIS document

- Further, the modelling found that: “In some cases, the one-hour future demand would exceed the road capacity. These calculated future demands were then flattened to correspond with anticipated peak spreading, allowing for a longer peak period” (Appendix G, p. 38), indicating that where modelling results were poor, this traffic was simply “spread” out and the assumption was made that some of this traffic could travel at other times—a measure that is difficult to justify considering the same practice might be used to improve future M5 “without project” modelling—simply by “flattening” use until the peak period spreads out sufficiently to improve network functioning

Travel around the St Peters interchange indicates low car mode share and high walking for Sydney and Marrickville LGAs, while Botany Bay’s mode share aligns closer with the greater Sydney average (see below)—indicating that those that stand to benefit most from the project are not those that face the impacts of the project being implemented

The report notes that there are seven well-serviced train stations in or in the vicinity of the study area (Newtown, Erskineville, Green Square, St Peters, Sydenham, Tempe, Mascot) and a comprehensive bus network services the surrounding job and activity precincts—what modelling has been undertaken to seriously investigate the possibility of better using this infrastructure as an alternative option to the M5 project? To what extent will these services suffer from a loss of patronage and changed traffic conditions (busses) as a result of the project?

In Ch 6 Existing road network performance, 6.1 Assessment criteria:

The report warns that following the project “there may be single locations where there may be improvement, while at others some deterioration” (Appendix G, p. 67)—do the “improvements” outweigh the “deterioration”, and the lack of improvement in many other instances, enough to warrant such an extensive project?

In describing LoS the report notes that “It should also be noted that capacity constraint can be used as a demand management technique which discourages car travel and that conversely over-provision of capacity can encourage more car use.” (Appendix G, p. 68)—does this suggest that when the M5 modelling produced poor results a low LoS became “a demand management technique”? Was the current situation, similar in that some intersections and road sections are operating at a low LoS, ever considered “a demand management technique”?

“The actual LoS would be worse than presented here, as the LoS only represents the satisfied demand (capacity) and, due to downstream congestion and queueing at these locations, they underestimate the actual demand”(Appendix G, p. 236)—yet instead of being a starting point for analysis of the pros and cons of this M5 project, these figures are used (regularly) as the final justification for this project. There is a need to be careful about how such figures are used, as they can seem very real and solid whereas they are certainly not guaranteed to happen

- “…Therefore, the v/c ratios and LoS should be seen as a base for comparison, or indication of change for future scenarios, rather than absolute values” (Appendix G, p. 69). Moreover, these present a “worst case scenario” of traffic and congestion: more recent trends such as “peak car” (seehttp://m4eis.org/2015/09/30/note-explaining-automobile-dependence-peak-car-use-and-induced-traffic/) would indicate that travel preferences are changing and that continuing to model upward trends of car use is an outdated (and risk-laden) assumption

- In addition to these issues with modelling, the scope of the project that is modelled does not allow for the full, system-wide effects of the operational project to be analysed sufficiently. Increasing the scope to a more appropriate scale for such a large project would go some way to identifying its true impact, and would also better allow the cumulative impacts of the project on traffic and transport to be gauged

“Modelling” future crashes, the results of which are used as a justification for the project within the report, is based on a simple assumption that “future frequency, type, and severity of crashes” would remain similar, so using this “formula” and given increasing traffic volumes an increase in predicted crashes is assured using such an approach. A more detailed and sensitive model might provide a more accurate estimate of future trends

- The report also states that crashes will decrease due to reduced congestion as a result of the project (Appendix G, p. 241-242), however no estimations are made regarding whether each crash that does occur will be more damaging, expensive and deadly due to higher speeds and changed traffic conditions

Levels of service (LoS) and volume to capacity ratios (v/c ratios) are advised to be only used as “a comparison, or indication of change between scenarios, rather than absolute values”—yet throughout the document these are used as if they are certainties. This further adds doubt to the economic viability of the project, given the difficult in estimating future patronage patterns

“There may be a shift to public transport as a result of the increase[d] travel times [under the “do minimum” scenario]” (Appendix G, p. 211)—little more is said on this point in the report, however this is certainly a viable (not to mention attractive, given that most cities are strategically aiming to curb car usage and encourage active and public transport) alternative at face value that should have been more thoroughly investigated

“For the purpose of assessing the impacts of the project on surrounding roads, with an exclusive focus on the study area rather the wider Sydney network, it is acknowledged that the adopted three stage approach: forecasting, rebasing and operational traffic modelling, provides a more accurate representation of how future year traffic growth would affect observed traffic demands than direct output from the WRTM. However, a wider assessment can also be undertaken using only traffic forecasting data as this provides evidence of high level patterns across parallel strategic corridors external to the study area for peak and daily time periods. Consequently, traffic volumes were directly sourced from the WRTM for key roads in the study area” (Appendix G, p. 221)—if both sources have acknowledged strengths and weaknesses why were both not used to gain a more thorough picture of local and wider functioning?

- As an example, the “Screenline” analyses is taken directly from the WRTM, it is not rebased as outlined elsewhere in the report (Appendix G, p. 222)

All modelled outcomes included in the report refer ultimately to the “full WestConnex and southern extension” scenario as that to best justify this project. However given that the complete WestConnex project has yet to gain planning approval, and especially considering that design and cost changes continue to impact on the project, this is difficult to justify. Would the M5 project stand up to scrutiny if it were assessed as a stand-alone project? What if the subsequent WestConnex project is delayed or not built?

- For instance “Although there is a significant increase in traffic demand in the 2031 ‘full WestConnex and future Southern extension’ scenario, the construction of Stage 3 provides the additional road space through the Sydney Gateway proposals and increases the ability to distribute and accommodate the predicted increase in local traffic” (Appendix G, p. 252), yet after saying this, details of how stage 3 will accommodate the additional traffic are not given, however then details are given for 2031 without the project/2031 including the full WestConnex project. It is misleading to only provide details of these two scenarios only, considering there is a possibility that Stage 3 will not gain planning approval or will not be deemed economically viable

- For instance, what would the results below look like if the “with project” (without the full WestConnex) modelling was included? (note that LoS D, E or F are all deemed necessary to require action to improve their situation by the RMS—do not simply assume that “green” equates to a good LoS!)

(Appendix G, p. 255)

“Based on the analysis of WRTM output and screenlines, traffic is forecast to divert off the motorway network to use other routes (in particular, Stoney Creek Road) outside the peak traffic periods to avoid the proposed toll” (Appendix G, p. 233)—the negative impacts of behaviour such as “rat-running” that tolls encourage are omitted from the report

At Level of Service (LoS D) or worse (D, E or F) actions are generally taken to resolve the problem, and the report states that pinch points, limited road capacity and built up areas in Sydney often lead to LoS E and F (“regularly experienced by motorists”)—“Roads and Maritime have a program of works aimed at relieving congestion at pinch points and improving performance on strategic roads”. The subsequent report reveals a number of roads and intersections that will operate at such a poor LoS—to build such an extensive and expensive project with numerous sections operating at LoS D, E or F immediately upon completion, whereby Roads and Maritime will have to “have a program of works” to address the situation straight away, suggests that the M5 and wider WestConnex project is an obsolete road and transport “solution”

- For instance the New M5, between Southern extension and St Peters interchange, is forecast to operate at LoS C in 2031

- The King Georges Road Interchange Upgrade is forecast to operate at LoS F in both AM and PM peaks in the ‘do minimum’ and ‘full WestConnex and Southern extension’ scenarios (Appendix G, p. 239)

- In 2021, at the St Peters interchange, “In both AM and PM peak hours, the network performance with the project improves slightly compared to the network performance without the project. In the AM peak hour, the average travel time per vehicle through the network reduces by nine per cent, with the average speed per vehicle increasing by 17 per cent. In the PM peak hour, the average travel time per vehicle through the network reduces by seven per cent and the average speed per vehicle increases by 16 per cent. This indicates a slight easing of congestion with the project in 2021” (Appendix G, p. 250)

- In 2031, with the M5 project, “there is a significant local increase in local trip generation which needs to be accommodated in the network” (Appendix G, p. 251)—this is not sufficiently addressed throughout the report

- From 2021 to 2031 under the “with project” (only the M5—not the entire WestConnex project) modelling, total network traffic demand is projected to increase by approximately 17% in the peak AM period, and 16% in the PM period, which then “needs to be accommodated without any increase in road space attributed to WestConnex Stage 3” and “paramics modelling suggests that only about 80 per cent of the traffic demand in the 2031 ‘with project’ [that is, without the other WestConnex projects being constructed] scenario could be accommodated in the network”(Appendix G, p. 252-253). How can a project for which the surrounding existing road network can only accommodate 80% of the traffic it generates be proposed as a “solution” to traffic congestion? What is the contingency plan if the subsequent WestConnex project is not undertaken?

- In 2031 the “without project” modelling for AM peak hour projects vehicles to travel through the area at 18.9km/h, while with the full WestConnex project plus the southern extension this rises to just 26.9km/h. Similarly, in the PM peak period, average speed rises from 16.3km/h to 28.3km/h. The resultant speeds remain insufficient to justify this project (and they themselves are reliant on the subsequent third WestConnex stage as mentioned above)

- Intersection LoS is projected to remain poor around the St Peters interchange area for AM peak hour levels (from 2 LoS D and 4 LoS F ratings without any of the project implemented to 5 LoS D and 3 LoS F with the full WestConnex project), and will also be poor for the PM peak hour which contains 2 LoS D, 3 LoS E and 3 LoS F intersections—the report itself states that “At LoS D or worse, actions are generally seen as necessary to resolve the problem” [which leads to questions of why LoS D is depicted as green in tables in the report, E as orange and F as red—surely LoS D and worse deserves to be graded “red”, or poor, for a new project billed as a “solution” to congestion?]

- “Due to the extensive change in the road layouts as part of the St Peters interchange and the local road upgrades, there are permanent impacts on property and business access and on street parking provision”—but these details are not given in this report making it difficult to evaluate their impact. What is known is that they will include additional parking at Campbell Street (34 on-street and 26 off-street spaces), loss of 44 spaces along Albert Street, loss of 111 spaces along Campbell Road, loss of 23 spaces along Burrows Road, loss of 24 spaces along Euston Road, loss of 28 spaces along Huntley Street, 18 less spaces on Princes Highway, 38 less spaces along May Street, 33 spaces lost along Unwins Bridge Road, possible loss of spaces along Brown, Florence, and St Peters Streets, loss of 47 on-street parks on Gardeners Road and loss of 16 off-street parks along Bourke Road (Appendix G, p. 268). An overall loss of 382 (and potentially more) parking spaces represents a significant impact on the local community, and as would be relevant for this section—will more restricted parking lead to additional localised traffic and parking issues?—such impacts are not addressed in the EIS report

To claim that the project aligns with Sydney’s Walking Future and Sydney’s Cycling Future, as is done the report, overlooks major aims of these documents such as increased mode share of active transport, improved pedestrian and cyclist safety and promotion of healthier lifestyles

In terms of management of impacts, the only management initiatives proposed in the report are that layout changes are designed to “complement and/or mitigate the impacts of the project”, undertaking an operational traffic review 12 months following operation of the project (by which time it would be too late to significantly address any of the flaws of the project, especially given that “The assessment has identified a number of intersections where the operational performance would change significantly under the future traffic demands as modelled”), and to engage in “integrated network and corridor planning processes” (including setting objectives, analysing actual versus projected performance, maintenance of existing control systems and identifying strategic funding priorities) (Appendix G, p. 270-271). No concrete and satisfactory management initiatives are proposed, and the “impacts” they will supposedly address are not given in any form of detail or consistency throughout the report

4.6 Conclusion

WAG formally and strongly objects to the traffic modelling and analysis of alternatives to building the WestConnex New M5 included in this EIS, and we ask that the Minister for Planning to reject the WestConnex New M5 project.